Privacy Policy

1. Overview

ZARIN Real Estate ("ZARIN", "we", "our", or "us") is a Dubai-based real estate advisory firm operating under UAE RERA licensing. This Privacy Policy explains how we collect, use, store, share, and protect personal data of clients, prospective clients, website visitors, and other individuals who interact with us.

This policy applies to all personal data processed by ZARIN through any channel — including our website at zarinrealestate.com, WhatsApp, phone, email, in-person meetings, and partner platforms. It is designed to comply with the United Arab Emirates Personal Data Protection Law (Federal Decree-Law No. 45 of 2021, "PDPL") and aligns with international standards including the EU General Data Protection Regulation (GDPR).

Real estate transactions involve significant personal and financial information. We treat this responsibility seriously. Every member of the ZARIN team — from advisors to administrative staff — is bound by confidentiality agreements and trained on data-handling protocols specific to the real estate industry. Independent of legal compliance, we operate by a simple principle: we treat your data the way we would want our own data treated.

If you have any questions about this policy or how we handle your personal data, you can reach our Data Protection Officer at privacy@zarinrealestate.com. We aim to respond to all privacy inquiries within five business days.

2. Data We Collect

We collect personal data that you provide directly, data generated through your use of our services, and data from public or licensed third-party sources. The categories we typically process include:

3. How We Use Your Data

We process your personal data only for specific, legitimate purposes. We do not engage in mass marketing, data broking, or selling your information. The uses below describe the primary ways your data is processed:

• ·Advisory services: to provide property recommendations, market briefings, and consultations tailored to your stated mandate. We process your preferences and budget to curate a relevant shortlist.
• ·Transaction execution: to facilitate property viewings, offers, contracts, escrow setup, and DLD title transfer. We process verification documents to meet UAE AML/CFT requirements.
• ·Communication: to respond to your inquiries, schedule meetings, and share updates relevant to your mandate. We do not send unsolicited marketing beyond occasional market reports — and only if you opt in.
• ·Service improvement: to analyze aggregated, anonymized usage patterns and improve our website, tools, and advisory processes.
• ·Legal & regulatory: to comply with UAE RERA, DLD, AML, and PDPL obligations, and to maintain records as required by law.
• ·Security: to monitor for fraud, unauthorized access, and other threats to our systems and clients.

4. Legal Basis for Processing

Under UAE PDPL and GDPR-aligned standards, we process personal data only when we have a valid legal basis. The following bases apply to our processing activities:

• ·Consent: when you submit a consultation request, subscribe to market reports, or accept non-essential cookies. You can withdraw consent at any time.
• ·Contractual necessity: to fulfill our advisory agreement with you, including property search, viewings, and transaction support.
• ·Legal obligation: to comply with UAE RERA, DLD, Central Bank, AML, and tax regulations that require us to verify identity and maintain transaction records.
• ·Legitimate interest: to communicate with you about your mandate, analyze anonymous usage data, and protect against fraud. Our legitimate interests never override your fundamental rights and freedoms.

5. Sharing & Disclosure

We do not sell, rent, or trade your personal data. We share data only with specific categories of recipients where it is necessary to deliver our services or comply with the law:

• ·Property developers & sellers: to arrange viewings, request pricing, and submit offers. We share only the information necessary for the specific transaction.
• ·UAE regulatory bodies: DLD, RERA, and the UAE Federal Tax Authority where reporting is mandated by law.
• ·Banks & mortgage providers: only with your written consent, to facilitate mortgage pre-approval and processing.
• ·Legal & escrow agents: licensed UAE advocates and regulated escrow agents for property transactions.
• ·Service providers: cloud hosting, CRM, and email tools that process data on our behalf under written data-processing agreements. We never allow these providers to use your data for their own purposes.

In rare cases, we may be required to disclose data to UAE law enforcement or judicial authorities pursuant to a valid legal order. We will challenge any overbroad request and notify you where legally permitted.

6. Storage & Security

Your personal data is stored on encrypted servers located in the United Arab Emirates, with backup infrastructure in the European Union. We use industry-standard security controls including TLS 1.3 encryption in transit, AES-256 encryption at rest, multi-factor authentication for all internal access, and role-based access controls that limit data visibility to the minimum necessary.

Access to client records is restricted to the assigned advisor and a small number of authorized operations staff. Every access is logged and audited. We conduct quarterly security reviews and annual third-party penetration testing to validate our controls.

Despite our efforts, no system can be guaranteed 100% secure. In the event of a personal data breach affecting your rights, we will notify the UAE Data Office and affected individuals within 72 hours of becoming aware, in line with PDPL requirements.

7. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes outlined in this policy and to meet our legal obligations. Specific retention periods include:

When retention periods expire, we either securely delete the data or anonymize it so that it can no longer identify you. If you would like us to delete your data earlier, you may submit a deletion request — see Section 8.

8. Your Rights

Under UAE PDPL and GDPR-aligned standards, you have the following rights regarding your personal data. To exercise any of these rights, contact us at privacy@zarinrealestate.com.

• ·Access: request a copy of the personal data we hold about you, free of charge, within 30 days.
• ·Correction: request correction of inaccurate or incomplete data.
• ·Deletion: request erasure of your data, subject to legal retention obligations.
• ·Restriction: request that we limit processing while a dispute is being resolved.
• ·Portability: receive your data in a structured, machine-readable format and transmit it to another provider.
• ·Objection: object to processing based on legitimate interests or for direct marketing.
• ·Withdraw consent: withdraw consent for processing at any time, without affecting the lawfulness of processing before withdrawal.
• ·Complaint: lodge a complaint with the UAE Data Office or your local data protection authority.

9. Cookies & Tracking Technologies

Our website uses cookies and similar technologies to operate essential functions and, where you consent, to analyze usage and personalize experience. We categorize cookies as follows:

You can manage cookies through the consent banner shown on first visit, through your browser settings, or by clearing cookies at any time. Disabling non-essential cookies will not affect your ability to use the website.

10. International Data Transfers

Because we work with international clients and use global cloud infrastructure, your personal data may be transferred outside the UAE. We only transfer data to countries that provide an adequate level of protection under UAE PDPL, or under appropriate safeguards such as Standard Contractual Clauses approved by the relevant regulator.

Where we use service providers located outside the UAE (for example, CRM, email, or analytics providers based in the EU or USA), we ensure they are bound by GDPR-compliant data processing agreements and certified under frameworks such as the EU-US Data Privacy Framework.

11. Children's Privacy

Our services are not directed at children under 18, and we do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us at privacy@zarinrealestate.com and we will take steps to delete such data.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, or legal requirements. When we make material changes, we will update the "Last reviewed" date at the top of this page and notify you by email if you have an active advisory relationship with us.

We encourage you to review this policy periodically. Continued use of our services after a change takes effect constitutes acceptance of the updated policy, to the extent permitted by law.

13. Contacting Us

If you have any questions, requests, or complaints regarding this Privacy Policy or your personal data, our Data Protection Officer is your point of contact:

You also have the right to lodge a complaint with the UAE Data Office if you believe we have not addressed your concern. We commit to engaging constructively with any regulator inquiry.